# E-Invoicing under GST [Rule 48(4)]
## What is E-Invoicing?
E-invoicing does NOT mean generating invoices on a Government portal. Taxpayers continue to generate invoices in their own accounting/billing/ERP systems. The invoice details are then reported electronically to the Invoice Registration Portal (IRP) as per the e-invoice schema.
### Process Flow
1. Supplier creates invoice in own ERP/billing software.
2. Invoice details uploaded in Form GST INV-01 on the IRP.
3. IRP generates a unique Invoice Reference Number (IRN) and digitally signs the e-invoice.
4. Signed e-invoice + IRN returned to supplier.
5. Invoice is valid only with a valid IRN.
> Currently covered: invoices, credit notes, debit notes issued by notified persons for B2B transactions and exports.
## Applicability — Who Must Issue E-Invoice?
Mandatory for taxpayers whose aggregate turnover (PAN-based) in ANY preceding FY from 2017-18 onwards exceeds Rs. 5 crore ("notified persons").
| Scenario | E-invoice Applicable? |
|---|---|
| Notified person — B2B supplies and exports | YES |
| Notified person — B2C supplies | NO |
| Notified person — supplies under RCM u/s 9(3) | YES (invoice issued by notified supplier) |
| Supplies received by notified person from unregistered persons under RCM u/s 9(4) / import of services | NO |
| Import of goods | NO |
## Persons EXEMPT from E-Invoicing
Even if turnover exceeds Rs. 5 crore, the following are exempt:
1. Special Economic Zone (SEZ) UNITS (note: SEZ developers are NOT exempt — they must issue e-invoices if turnover > Rs. 5 crore)
2. Insurer / Banking Company / Financial Institution including NBFC
3. GTA (Goods Transport Agency) supplying transportation of goods by road in a goods carriage
4. Supplier of passenger transportation services
5. Supplier of services by way of admission to exhibition of cinematograph films in multiplex screens
6. Government Department / Local Authority
> Supplies TO SEZ units: A notified person supplying to an SEZ unit must still issue an e-invoice — exemption is from the SEZ unit's own outward supplies, not from receiving e-invoices.
> Mandatory Declaration: Exempt taxpayers (above the e-invoice threshold but in an exempt category) must add a declaration on the invoice stating they are not required to issue an e-invoice despite crossing the threshold.
## Statutory Hooks [Rule 48(4)]
- Notified registered persons must prepare invoice by uploading details in Form GST INV-01 and obtaining an IRN.
- The Commissioner, on Council's recommendation, may exempt persons/classes for a specified period, with conditions.
- An invoice issued outside Rule 48(4) by a notified person is NOT a valid invoice.
- Where e-invoicing applies, no triplicate / duplicate copies are required (digital IRN-backed copy is the valid invoice).
## Advantages of E-Invoicing
1. Auto-population of B2B invoice data into GST returns and auto-generation of e-way bills — reduces duplication across GSTR-1 and e-way bill.
2. Fewer transcription errors — same data flows to tax department and buyer, easing reconciliation with the Purchase Order.
3. Standardisation & interoperability — fewer disputes, faster payment cycles, better efficiency.
4. Complete trail of B2B invoices enables system-level ITC vs output tax matching — reduces evasion.
5. Curbs fake invoices — real-time data access to tax authorities helps eliminate fraudulent ITC claims.